Summary

We are pleased that the consultation proposes to make changes to the system of LHA. While we support the Governments underlying principles of LHA we feel there are still problems with the system that need to be addressed to make it efficient, fair and fit for purpose. In particular, we are pleased to see the consultation is seeking views on how appropriate boundary areas used to calculate HB should be set.

We are disappointed, however, that the consultation fails to address one of the biggest issues highlighted by claimants, private landlords, voluntary organisations and local authorities – that presumption of payment to the claimant is not working. Our research shows that most claimants with experience of both payment of LHA direct to their landlord

and to them would prefer the former.

We are also concerned with proposals in the consultation that seek to link HB to housing conditions and energy efficiency, placing responsibility on the tenant. An unintended consequence of linking HB to housing standards would be to reduce supply and thereby make it even more difficult to for people on the lowest incomes to find an affordable home.

Finally, we are very concerned that the focus of the consultation is the level of benefit deemed appropriate to the taxpayer. The rising HB bill is a result of the shift away from bricks and mortar investment in social housing, the deregulation of private rents and the increasing reliance on the private rented sector to house people in desperate need of a home. Attempts to reduce the HB bill by further restrictions in payment will only lead to increased shortfalls and therefore poverty, homelessness and social exclusion. We need to be asking more fundamental questions concerning the supply of affordable and accessible properties for benefit claimants, rather than using the benefit system as a blunt tool for housing stock improvements.